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HC upheld the validity of Rule 36(4) in CGST and TNGST Rules, which restricts Input Tax Credit (ITC) availment when suppliers fail to upload invoices under Section 37(1). The court determined that the rule was a temporary regulatory measure to protect government interests and taxpayers from potential recovery proceedings. The restrictions were deemed constitutionally valid and not violative of Article 14, with the amendment designed to ensure partial ITC availability while maintaining compliance mechanisms. The court emphasized that the rule's implementation was a proportionate response to systemic challenges in tax credit documentation, effectively rejecting the constitutional challenge to the regulatory provision.
HC upheld the validity of Rule 36(4) in CGST and TNGST Rules, which restricts Input Tax Credit (ITC) availment when suppliers fail to upload invoices under Section 37(1). The court determined that the rule was a temporary regulatory measure to protect government interests and taxpayers from potential recovery proceedings. The restrictions were deemed constitutionally valid and not violative of Article 14, with the amendment designed to ensure partial ITC availability while maintaining compliance mechanisms. The court emphasized that the rule's implementation was a proportionate response to systemic challenges in tax credit documentation, effectively rejecting the constitutional challenge to the regulatory provision.
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